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Subrecipient Monitoring

Subrecipient Monitoring. OMB Circular A-133 requires that subrecipients comply with federal audit requirements. Subrecipients must also comply with OMB Circulars A-21 and A-110 for cost principles and uniform administrative requirements.

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Subrecipient Monitoring

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  1. Subrecipient Monitoring • OMB Circular A-133 requires that subrecipients comply with federal audit requirements. • Subrecipients must also comply with OMB Circulars A-21 and A-110 for cost principles and uniform administrative requirements. • Institution receiving prime award has a responsibility to monitor activities of subrecipients. OPAA 6/09

  2. Subrecipient Monitoring • Agreements are Known as: • Subawards • Subcontracts • Subgrants • Subrecipients OPAA 6/09

  3. Subrecipient Monitoring What is a Subagreement? • An agreement that is written under the authority of and consistent with, the terms and conditions of a prime award and authorizes a portion of the research or substantive effort to be performed by another organization.. OPAA 6/09

  4. Subrecipient Monitoring Has programmatic responsibilities Performance is measured against the project objectives or scope of work. • The Subrecipient functions as a co-investigator on the project. OPAA 6/09

  5. Subrecipient Monitoring • Subrecipient Agreements: • Sponsor prior approval is required. • Subrecipients should be identified in the proposal. • Scope of work to be completed should be included. • Subrecipient costs should be included in the proposal budget. OPAA 6/09

  6. Subrecipient Monitoring • Subrecipient Agreements: • All terms and conditions of the prime award are included in the subaward. • Program compliance requirements are passed down to subrecipient. • Terms to include: • Financial and technical reporting requirements. • Any required cost share. OPAA 6/09

  7. Subrecipient Monitoring • Subagreements: • Terms to include: • Payment terms. • Audit clauses. • Record retention requirements • Access to records. • Agreements are prepared by Sponsored Programs Office. • Signature of acceptance of these terms by the receiving entity is required. OPAA 6/09

  8. Subrecipient Monitoring • Prime Institution Responsibilities Include: • Write the subaward, including scope of work. Attach a copy of the prime award. • Communicate with key personnel listed in subaward. • Ensure all reporting obligations are met. • Verify that subaward scope of work has been completed. • Monitor for compliance with award terms and conditions and federal requirements. OPAA 6/09

  9. Subrecipient Monitoring • PI / Dept / Business Center Monitoring Procedures: • Review budget line item detail of invoices for compliance with regulations. • Is amount requested within contract amount? • Are the invoice dates within time period of award? • Verify with Principal Investigator that sufficient progress is being made. OPAA 6/09

  10. Subrecipient Monitoring • OPAA Monitoring Procedures: • Request annual audit report. • Facilitate closing of the subaward. • Before the final invoice is paid: • Collect financial and technical reports • Collect cost share and equipment reports, if needed. • Obtain subrecipient release documents. • Assure compliance with all terms of the award OPAA 6/09

  11. Subrecipient Monitoring • Subrecipient Responsibilities include: • Compliance with award terms and conditions; OMB circulars A-110, A-21 and A-133. • Obtain independent audit. • Submit results of A-133 audit to prime institution. Any audit findings affecting award must be disclosed. • Submit invoices to prime recipient, including budget line item detail. OPAA 6/09

  12. Subrecipient Monitoring • Subrecipient Responsibilities include: • Communicate with prime recipient Principal Investigator. • Ensure all financial and technical reporting requirements are met. • Comply with record retention requirements. • Maintain financial systems and accurate records identifying project expenses. OPAA 6/09

  13. Subrecipient Monitoring • Special Considerations: • Foreign, industry, commercial, and non profit organizations are not subject to the OMB circular costing, uniform administrative or audit requirements. • Individual monitoring plans must be developed. • Make sure the organization agrees to the monitoring plan. OPAA 6/09

  14. Subrecipient Monitoring • Remember: • The legal relationship is between the prime recipient and the subrecipient. • All communications from the subrecipient must be to the prime recipient and not directly with the sponsoring agency. • There must be a statement of work concise as to what, when, and how the subrecipient tasks will be accomplished. OPAA 6/09

  15. Subrecipient Monitoring • Remember: • Flow down correct regulations. • Grants and Cooperative agreements – flow down OMB Circulars. • Contracts – flow down FAR clauses. • Contact the Office of Post Award Administration if there are any issues regarding this Subagreement, including issues of non-payment. OPAA 6/09

  16. Subrecipient Monitoring • Remember: • Sanctions and penalties applied to the prime recipient when subawardee fails to comply: • Non performance • Violating regulations • Mismanagement of award You are responsible for the actions of your subrecipients! OPAA 6/09

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